On March 19 and 20 the OECD will hold its public consultation on action points 8, 9 and 10 of the base erosion and profit splitting (BEPS) project.

Topics on the agenda include:

  • recharacterisation of risk allocations for transfer pricing purposes, considering the contractual allocation of risk between group companies and the functions performed to control risk
  • several ‘special measures’ proposed by the OECD in relation to the allocation of capital for transfer pricing purposes, transfers of hard to value intangibles, minimal functional entities and CFC rules
  • the use of profit split methods
  • low value-adding intra –group services

We have a dedicated global BEPS team that tracks the BEPS developments closely and will report on progress against the action plan.